Junius Robinson v. Capital Staffing

CourtLouisiana Court of Appeal
DecidedOctober 18, 2017
DocketWCA-0017-0114
StatusUnknown

This text of Junius Robinson v. Capital Staffing (Junius Robinson v. Capital Staffing) is published on Counsel Stack Legal Research, covering Louisiana Court of Appeal primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Junius Robinson v. Capital Staffing, (La. Ct. App. 2017).

Opinion

STATE OF LOUISIANA COURT OF APPEAL, THIRD CIRCUIT

17-114

JUNIUS ROBINSON

VERSUS

CAPITAL STAFFING, ET AL.

**********

APPEAL FROM THE OFFICE OF WORKERS’ COMPENSATION - # 3 PARISH OF CALCASIEU, NO. 15-06229 CHARLOTTE L. BUSHNELL, WORKERS’ COMPENSATION JUDGE

ELIZABETH A. PICKETT JUDGE

Court composed of Marc T. Amy, Elizabeth A. Pickett, and Billy Howard Ezell, Judges.

REVERSED.

Michael B. Miller Attorney at Law P. O. Drawer 1630 Crowley, LA 70527-1630 (337) 785-9500 COUNSEL FOR PLAINTIFF-APPELLEE: Junius Robinson

Eric E. Pope Pamela Noya Molnar Blue Williams, L.L.P. 3421 N. Causeway Blvd., Suite 900 Metairie, LA 70002 (504) 831-4091 COUNSEL FOR INTERVENOR-APPELLANT: South East Personnel Leasing, Inc. PICKETT, Judge.

The employer in this workers’ compensation suit appeals a judgment that

awarded the employee penalties and attorney fees against it because the employer

improperly suspended the employee’s indemnity benefits after he failed to attend

two medical examination appointments that it scheduled. For the following

reasons, we reverse the judgment.

FACTS

On October 2, 2015, Junius Robinson filed an LDOL 1008 claim, alleging

that he was injured while working in the course and scope of his employment with

LA Rice Mill, Inc. and Capital Staffing. These two defendants denied employing

Mr. Robinson. South East Personnel Leasing, Inc. (South East) filed a petition of

intervention in which it averred that Mr. Robinson was its employee and that he

was leased to its client, Capital Welding Fabrication, Inc. South East assumed the

defense in this matter.

Upon issuing indemnity benefits to Mr. Robinson, South East scheduled an

appointment for him to be examined by Dr. Harold Granger on November 30, 2015.

Mr. Robinson missed the appointment, and South East rescheduled the

appointment for January 11, 2016. Mr. Robinson arrived at the appointment more

than forty-five minutes late and was informed that Dr. Granger had left his office

for the day.1 South East suspended Mr. Robinson’s indemnity benefits after he

missed the second appointment with Dr. Granger but reinstated those benefits on

approximately April 14, 2016, after he was examined by Dr. Granger.

In June 2016, Mr. Robinson filed a motion seeking penalties and attorney

fees for the suspension of his benefits. After a hearing, the workers’ compensation 1 Without objection, Mr. Robinson’s counsel entered documentation into evidence which he argued showed that the November appointment was rescheduled because the defendant failed to forward Mr. Robinson’s medical records to Dr. Granger’s office for the January 11 appointment. South East countered that argument with documentation from Dr. Granger, stating he would have conducted the examination without Mr. Robinson’s records if he had been present for the appointment. judge (WCJ) determined that South East violated the workers’ compensation law

by suspending Mr. Robinson’s benefits without first obtaining an order compelling

his attendance at the medical examination and awarded Mr. Robinson $8,000 in

penalties and $6,000 in attorney fees.

South East filed a writ application with this court, seeking reversal of the

judgment on the basis of four assigned errors. Upon review of the writ application,

another panel of this court concluded that the WCJ’s judgment at issue herein is a

final appealable judgment and converted the writ application to an appeal. See

Junius Robinson v. Capital Staffing, 16-829 (La.App. 3 Cir. 12/1/16) (unpublished

writ decision).

ASSIGNMENTS OF ERROR

South East urges that the WCJ committed the following errors that warrant

reversal of the judgment against it:

1. The lower Court erred in ruling that an Employer is required to obtain an order compelling a Claimant to attend a second medical opinion appointment prior to the suspension of benefits, in light of the amendments to La.R.S. 23:1124, and in awarding penalties and attorney[] fees as a result.

2. The lower Court erred in failing to allow Employer’s claims adjuster to testify that the Claimant was served via certified mail when analyzing Employer’s compliance with La.R.S. 23:1201.1(A)(4) and (5).

3. The lower Court improperly awarded attorney[] fees and penalties at this intermediate juncture of the proceeding, as litigation is ongoing and the Court’s ruling has the potential to subject Employer to additional attorney[] fees and penalties in violation of the [Workers’] Compensation Act.

4. The lower Court erred in the amount of penalties and attorney[] fees it awarded given the amount of legal work involved [in] the filing and appearance at a hearing for one motion[] and [in its assessment of] the maximum penalty prior to the case proceeding to formal hearing.

2 DISCUSSION

South East defends against Mr. Robinson’s claims for penalties and attorney

fees, arguing that its suspension of Mr. Robinson’s benefits without first obtaining

an order compelling his attendance at the examination is authorized by

La.R.S. 23:1124 in conjunction with La.R.S. 23:1201.1(A)(4) and (5). Prior to the

hearing on Mr. Robinson’s claims, South East requested that the hearing be

converted to a preliminary determination hearing. See La.R.S. 23.1201.1(H),

which allows employers to obtain preliminary determinations on various disputed

issues that arise in the course of litigating workers’ compensation claims. Before

the hearing began, the WCJ denied South East’s request because it failed to seek a

preliminary determination as provided in Subsection 1201.1(H) in conjunction

with Subsection 1201.1(G).

At the conclusion of the hearing, the WCJ took the matter under advisement.

Thereafter, the WCJ issued oral reasons for judgment finding that because South

East did not follow the procedure for a preliminary determination hearing set forth

in Section 1201.1, Mr. Robinson was entitled to penalties and attorney fees and

awarded him $8,000 in penalties and $6,000 in attorney fees. The WCJ did not

address South East’s defense that it was not responsible for penalties and attorney

fees because it followed the procedure set forth in Section 1124 when it suspended

Mr. Robinson’s benefits.

Mr. Robinson counters South East’s defense on two bases: (1) no case has

held that an employee’s indemnity benefits can be suspended under Section 1124

without a court order compelling his attendance at a medical examination, and (2)

South East failed to prove that it followed the procedure outlined by Subsection

1201.1(A)(4). In 2013, the legislature amended Section 1124 and enacted Section

1201.1. See Acts 2013, No. 337, § 1. None of the cases cited by Mr. Robinson 3 involved the application of the current version of Section 1124 to claims arising

after 2013, when it became effective, and this court has not found any case in

which the suspension of indemnity benefits as provided by the current version of

Section 1124 was at issue.

Effect of 2013 Legislation

South East argues that Section 1124, as amended in 2013, provides

employers two procedural options for suspending benefits when employees fail to

attend medical examinations. Specifically, South East asserts that the first option

allows employers to suspend benefits if the suspension is done in accordance with

the requirements of Subsections 1201.1(A)(4) and (5), but the second option is

executed by the WCJ upon the employer’s motion to compel an examination. We

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Junius Robinson v. Capital Staffing, Counsel Stack Legal Research, https://law.counselstack.com/opinion/junius-robinson-v-capital-staffing-lactapp-2017.